giuffre-maxwell
gov.uscourts.nysd.447706.1328.33
3 pg
…contained in this e-mail and any attachments is confidential and may be privileged or otherwise
protected from disclosure. It is intended solely for the attention and use of the named addressee(s). If you are
not the intended recipient…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.10
28 pg
…84112
Tel: (801) 585-52021
1
This daytime business address is provided for identification and correspondence purposes only and is
not intended to imply institutional endorsement by the University of Utah for this private representation.
Case 1:15-cv…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.11
12 pg
…produced in this litigation is from July 18, 2009.
(GM_00069). Ms. Giuffre is aware of two email addresses that appear to be the email addresses
Defendant used while Ms. Giuffre was with Defendant and Epstein, namely, from 2000 - 2002.
…
giuffre-maxwell
gov.uscourts.nysd.447706.1094.0
40 pg
…UT 84112
(801) 585-52022
2
This daytime business address is provided for identification and correspondence purposes only
and is not intended to imply institutional endorsement by the University of Utah for this private
representation.
9
…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.1
3 pg
…UT 84112
(801) 585-52021
1
This daytime business address is provided for identification and correspondence purposes only and is
not intended to imply institutional endorsement by the University of Utah for this private representation.
…
giuffre-maxwell
gov.uscourts.nysd.447706.1200.12_1
4 pg
…UT 84112
(801) 585-52021
1
This daytime business address is provided for identification and correspondence purposes only and is
not intended to imply institutional endorsement by the University of Utah for this private representation.
…
giuffre-maxwell
gov.uscourts.nysd.447706.1300.0
4 pg
…the updated Order and Protocol for Unsealing Decided Motions,
ECF No. 1108, I used best efforts to identify the most current addresses for J. Doe 93 through J.
Doe 187.
8. I mailed the following documents to the Non-Parties…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.27
3 pg
…contained in this e-mail and any attachments is confidential and may be privileged or otherwise
protected from disclosure. It is intended solely for the attention and use of the named addressee(s). If you are
not the intended recipient…
giuffre-maxwell
gov.uscourts.nysd.447706.1294.0
11 pg
…ii) clarify
whether it will accept and maintain as confidential additional
ex parte submissions in further support of her request to seal,
(iii) establish a schedule to address the issues related to the
sealing of documents pertaining to Doe 171…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.14
4 pg
…for Production served on Ms.
Maxwell, nor the Court’s Orders limiting those requests.
Terramar –
Search term 49 is “Terramar.” While we are searching our client’s terramar email address for otherwise responsive
documents, this search term would pull up…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.23
4 pg
…UT 84112
(801) 585-52021
1
This daytime business address is provided for identification and correspondence purposes only and is
not intended to imply institutional endorsement by the University of Utah for this private representation.
…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.14
4 pg
…UT 84112
(801) 585-52021
1
This daytime business address is provided for identification and correspondence purposes only and is
not intended to imply institutional endorsement by the University of Utah for this private representation.
…
giuffre-maxwell
gov.uscourts.nysd.447706.1289.0
3 pg
…which the Court already considered. Doe
171’s motion also does not directly address the Court’s sound and obvious reason for unsealing,
which is that numerous public sources, including a federal complaint she herself voluntarily filed,
have already identified…
giuffre-maxwell
gov.uscourts.nysd.447706.1168.0_2
2 pg
…on an ad hoc basis. In her Reply, Ms.
Maxwell needed to address a significant number of legal and factual issues raised by plaintiff
in her Objections, including clarifying the record regarding Non-Party Notices, the effect of
the various…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.46
14 pg
…2
B. Plaintiff failed to produce emails from her iCloud and Hotmail accounts....................... 4
C. Plaintiff failed to address issue of her employment records ............................................ 5
D. Newly obtained education records and other witness testimony contradict Plaintiff’s
…
giuffre-maxwell
gov.uscourts.nysd.447706.1267.0
2 pg
… and (2) remove
Sanford Bohrer, whose email address is [email protected], from the list of counsel to
receive electronic filings in this case.
Case 1:15-cv-07433-LAP Document 1267 Filed 08/09/22 Page 2…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.24
4 pg
…UT 84112
(801) 585-52022
2
This daytime business address is provided for identification and correspondence purposes only and is
not intended to imply institutional endorsement by the University of Utah for this private representation.
…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.12
4 pg
…UT 84112
(801) 585-52021
1
This daytime business address is provided for identification and correspondence purposes only and is
not intended to imply institutional endorsement by the University of Utah for this private representation.
…
giuffre-maxwell
gov.uscourts.nysd.447706.1224.0
6 pg
…20-22. Plaintiff agrees, and proposes that Court address all
of the Non-Party Objections submitted and the documents those objections pertain to. Pursuant to
section 2(d) of the Court’s Order and Protocol for Unsealing Decided Motions, sixteen…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.13
15 pg
…INTRODUCTION
Ms. Ransome’s Opposition to Defendant’s Combined Motion to Compel (“Opposition”)
(Doc. 700), fell woefully short of actually addressing the categories of documents and deposition
questions sought by the Motion. While Ms. Ransome touts her “robust” production, in…